In Johnson v. McIntosh, Chief Justice John Marshall proclaimed that European discovery of America Agave exclusive title to those who made it;@ and diminished the power of Indians Ato dispose of the soil at their own will ….@ 21 U.S. 543, 574 (1823). Marshall presented a revised version of the discovery doctrine in Worcester v. Georgia, 31 U.S. 515 (1832), yet it is Johnson that remains the leading decision on native property rights in the United States. The Johnson discovery rule has not only diminished native rights in the United States, but has also influenced the definition of indigenous land rights in Australia, Canada, and New Zealand. This article describes the impact of the American doctrine of discovery in the aforementioned countries. The article sheds light on how John Marshall’s ideas influenced the views of British and colonial authorities with respect to the rights of the Australian Aborigines, the Mâori of New Zealand, and the First Nations of Canada. The article also examines the current status of indigenous land rights in Australia, Canada, and New Zealand. The article concludes with a brief discussion of the United Nation’s Declaration on the Rights of Indigenous Peoples, which affirms indigenous peoples’ rights to land and resources. Although Australia, Canada, New Zealand, and the United States voted against the 2007 Declaration, each country has reconsidered its position in the last two years. The legitimacy of the doctrine of discovery is being challenged in the United States and elsewhere.